Administrative delay and file movement do not constitute sufficient cause for condonation of delay.

The appellants challenged the judgment and award dated 4 October 2023 in LAC No. 2820/2021, passed by the III Additional District Judge and Additional Land Acquisition, Rehabilitation and Resettlement Authority, Vijayapura.

The appeal was filed on 30 July 2025 with a delay of 559 days. The appellants sought condonation of delay, attributing it principally to administrative reasons and movement of files.

The High Court found that the supporting affidavit was bald, lacked relevant dates, and did not explain the entire period of delay.

The appeal was brought under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act.

The Court applied the principles governing condonation of delay under Section 5 of the Limitation Act, including that an applicant must provide a reasonable and satisfactory explanation covering the period of delay; the State receives no automatic or special indulgence; and administrative lethargy or file movement, without a sufficient explanation, does not justify condonation.

Relying on Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, and State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191, the Court emphasized diligence, accountability, and finality in litigation, and held that delay cannot be condoned merely in the name of public interest or on the basis of bureaucratic inefficiency.

The appellants’ affidavit relied largely on file movement and administrative approvals but supplied no relevant dates or account of bona fide efforts to file within the limitation period. The explanation neither covered the full 559-day delay nor demonstrated reasonable and vigilant conduct.

Applying the cited Supreme Court principles, the Court held that these assertions amounted to an excuse rather than a satisfactory explanation, and that the State and its instrumentalities were not entitled to a more lenient standard.

It dismissed I.A. No. 01/2026 seeking condonation of delay and, consequently, dismissed the appeal. Pending applications, if any, were disposed of.